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Taking responsibility for border security: commercialinterests in the face of e-BordersJournal ItemHow to cite:

Dibb, Sally; Ball, Kirstie; Canhoto, Ana; Daniel, Elizabeth M.; Meadows, Maureen and Spiller, Keith (2014).Taking responsibility for border security: commercial interests in the face of e-Borders. Tourism Management, 42(1)pp. 50–61.

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1

Taking Responsibility for Border Security:

Commercial Interests in the face of e-Borders

Professor Sally Dibb*

Open University Business School

Walton Hall

Milton Keynes, MK7 6AA, UK

Tel: +44(0)1908 652787

Email: [email protected]

Dr KirstieBall


Walton Hall


Tel: +44(0)1908 655888


Dr Ana Canhoto

Oxford Brookes Business School

Wheatley Campus

Oxford, OX33 1HX, UK

Tel: +44 (0)1865 48 58 58


Professor Elizabeth M. Daniel


Walton Hall

Milton Keynes. MK7 6AA, UK

Tel: +44(0)1908 654572


Maureen Meadows


Walton Hall


Tel: +44(0)1908 655888


Dr Keith Spiller


Walton Hall


Tel: +44(0)1908 332436


Acknowledgements

The authors would like to thank the Leverhulme Trust for funding the study reported

in this paper. They would also like to thank the managers and staff in the

organizations that participated in this study for sharing their expertise.

2

ABSTRACT

Security is an important feature of the macro environment for tourism that affects the

consumption of travel products. Following high-profile terrorist attacks, UK border

security measures have been increased through the implementation of the e-Borders

programme. This initiative requires passenger carriers to collect and electronically

transmit travel document information and service information for any individual

entering or leaving the UK. The commercial impact of e-Borders on travel firms is

investigated by examining the relationships between the affected stakeholders,

considering the power and decision making at play, and exploring the outcomes. The

e-Borders programme is described, and a framework for the in-depth, qualitative

study is presented. The findings show that passenger carriers and travel firms manage

the negative consequences of compliance and restore their commercial interests by

engaging in a process we describe as recognizing, rationalizing and refashioning.

The implications for research and practice are explored.

Keywords:

Border security; e-Borders; stakeholder theory.

3

1. Introduction

Tourism research often focuses on individual case studies (e.g., Pearce, 2001), with

the consequence that it may fail to consider how wider trends impact on the industry.

Yet as a global activity, tourism is deeply affected by phenomena such as

globalisation and the networked economy (Witlox, Vereecken & Derudder, 2004),

while the discretionary nature of leisure travel means that demand is strongly

impacted by context (Pearce, 2005). Therefore, research in tourism must take into

consideration the macro setting in which tourism activity occurs (Ashworth & Page,

2011).

Security is a key feature of the macro environment. It affects the preferences and

behaviours of individual tourists (Hall, Timothy, & Duval, 2004), the activities of

businesses operating in the industry (Fuchs & Reichel, 2011) as well as wider

perspectives, such as the promotion of regional peace or the control of infectious

disease (see Isaac, 2010; Yu, 2012). Therefore, it is common to witness government

intervention and policy change in the aftermath of events that threaten homeland

security (Birkland, 2006). One important area of government intervention concerns

the protection of national borders, specifically decisions concerning who is allowed to

cross such borders (Timothy, 2001). Following high profile terrorist attacks in the

US, UK and elsewhere, the scrutiny of cross-border passenger traffic is deemed

essential for blocking the entry of problematic individuals (Salter, 2004) such as

terrorists. In the UK, such concerns have led to the development of a wide-ranging

counter-terrorism initiative known as e-Borders. Through this initiative, which

involves monitoring the movement of people across national borders, the UK Borders

Agency on behalf of the government, requires passenger carriers to collect customer

identity and behaviour data on its behalf (Whitley & Rukanova, 2008).

From the carriers’ viewpoint these requirements represent a major change in the

macro setting and have the potential to affect the operational and commercial aspects

of their business. When disruptions to the macro environment occur, organizations

typically move to protect their commercial position (Smart & Vertinsky, 1984). For

carriers, e-Borders has the potential to threaten these interests because of the

operational costs involved in implementing the initiative and its potential to damage

customer relationships. The industry is already being affected by other major changes

in the macro environment, such as the effects of increased Airport Passenger Duty

(APD) [ABTA, 2013]; the EU’s Emission Trading System (ETS) [European

Commission, 2013]; and the challenge from online retail and the breaking up of the

travel supply chain. Additional disruption that threatens the status quo by making it

more difficult for firms to keep operating costs low will be unwelcome. Furthermore,

e-Borders implies a major change in the role of carriers, as well as in the relationship

and balance of power between these businesses and the government. Potentially this

initiative also has implications for the carriers’ relationships with their customers and

other stakeholders, including other travel organizations in the supply chain. An

4

understanding of the real cost of e-Borders and how that cost is implemented down

the supply chain and spread among industry players is therefore essential.

Consequently, we investigate the following research question: What is the impact of

e-Borders on the carriers’ relationships with their customers and other stakeholders?

In considering the impact of e-Borders, as advocated by Faulkner (2001) and Scott

and Laws (2005), we look beyond the phenomena and explicitly consider the effects

of the initiative on the system. We do this by examining the interactions between

stakeholders at the micro level, in order to understand the impact on affected parties

of this macro-level change in the regulatory environment. In line with other studies of

stakeholder collaboration in tourism management research (see Arnaboldi & Spiller,

2011), we focus on three broad areas: i) the identification of key stakeholders and

their interests; ii) the collaborative process; and iii) the long-term structure and

outcomes of the multi-stakeholder process. We use the framework to reveal that

carriers and travel organizations engage in a process of recognizing, rationalizing and

refashioning in order to manage the negative consequences of compliance and restore

their commercial interests. Although our study focuses on the UK, it is an example of

a wider phenomenon of passenger data capture by airlines and so will be of interest to

those operating in and researching other territories.

After describing the e-Borders programme and identifying emerging issues, we

present the framework around which the study is based. The findings are presented

and discussed and the implications for further research and practice are considered.

2. The e-Borders programme

The e-Borders programme is a UK government initiative to monitor all movements of

people across the national borders and, in this way, ‘to support an intelligence-led

approach to border control’ (UK BA, 2009). It is typical of EU-wide and US

initiatives to prevent risky individuals from entering or leaving territories, which have

grown apace since the 9/11 terrorist attacks (Surveillance Studies Network 2006;

2010).

The programme requires that all travel carriers collect and electronically transmit

travel document information - also called advanced passenger information (API, the

collection of which is referred to as APIS) - as well as service information, for all

individuals travelling out of the EU. Data must be transferred to the UK Border

Agency (UK BA), between 24 hours and 30 minutes before travel. The UK BA

checks the details against watch lists of individuals judged to pose a risk to national

security and analyses the data for unusual patterns of travel behaviour. Where

concerns arise, alerts are generated for border staff, including police, immigration and

customs officers. Although currently only air carriers are required to do so, by 2014 it

is proposed that all air, sea and rail carriers must comply (Home Affairs Committee,

2009). As part of the e-Borders programme, carriers are also responsible for

5

collecting data from organizations that sell seats on their aircraft on their behalf.

Specifically, travel agents, tour operators and seat brokers are all affected by e-

Borders and have developed processes and implemented systems to collect and

transfer the required information to the carriers. The e-Borders initiative has

encountered a number of problems since its inception. The launch was moved from

May to October 2009 after airlines cautioned that introducing the system during the

peak holiday season would lead to chaos (Millward, 2009). In turn, the EU warned

that freedom of movement within the EU meant that, ‘citizens who refused to pass on

their personal information could not be stopped from entering or leaving Britain’

(Whitehead, 2009, p.12). This situation has not been resolved. While the EU has

suggested that European Citizens may opt out of providing data, the UK has

challenged this advice and the two parties are still in dialogue. In July 2010, the

government sacked the main IT contractor in the supplier consortium, Raytheon, due

to significant delays in delivery (Kollewe, 2010; Ford, 2010). After Raytheon was

sacked, new suppliers were brought in on temporary contracts. For example, IBM

and Serco were employed to implement the system before and during the Olympic

Games in London 2012. While the scheme continues to operate, those involved face

changing requirements and considerable uncertainty, as noted by the Home Affairs

Committee (2012), who ‘remain concerned about progress on the programme’.

The e-Borders programme is symptomatic of what has been seen as a blurring of

surveillance processes across public-private boundaries (Surveillance Studies

Network, 2006; 2010). Like other regulatory control initiatives, it relies on

information gathering, standard setting and behaviour modification (Hood et al.,

2001). The rationale for involving commercial organizations in a government’s

national security programme is that these firms have direct contact with their

customers, enabling them to collect passenger identity and travel behaviour data.

Bennear (2006) argues that non-state regulation works best: (i) when the

organizational population is diverse so they can choose their response; (ii) where the

information collection burden on the regulatory body would be very high if

information collection was not decentralized; and (iii) where the risks associated with

regulation are uncertain. If we follow Bennear (2006), from the government’s point

of view the design of the e-Borders programme, where air carriers have to collect data

from other companies and their customers, seems an efficient choice.

However, Coglianese and Nash (2006) assert that moving regulation to private sector

companies has operational implications for these companies, and will ‘penetrate and

shape what goes on inside private sector firms’ (p.3). Furthermore, Porter (2011)

cautions that whilst regulators can determine the objectives or targets of regulation,

they should not mandate the approach to meeting the regulation, which he sees as

‘blocking innovation and almost always inflicting cost on companies’ (p.74).

Ultimately, the success of the initiative depends on the individual organizations’

response to the regulation which is affected by within-firm priorities, the attitudes of

management to the regulation and the firm’s ability to respond (Kagan, 2006).

6

The disruption which e-Borders has caused is to the regulatory environment of travel

firms, yet the aspects affecting the initiative’s success are the same as those associated

with any upheaval in the macro setting. Smart and Vertinsky (1984) suggest that if

the external environment is perceived as very complex, turbulent and uncertain, then

firms often respond by engaging in short term ‘fire-fighting’, adaptive responses and

retrenchment. Managers who are trying to respond to the disruption and uncertainties

caused by e-Borders are therefore unlikely to feel that they can control events, or that

they have sufficient lead-time to make radical change or to be more entrepreneurial.

Consequently, we would expect them to react in an adaptive way (Smart & Vertinsky,

1984). Initially this might involve making operational changes to meet the immediate

regulatory needs; whereas later on, industry players might engage in responses

designed to restore their commercial interests. Even so, the effects of disruption to

the macro setting are unlikely to be evenly shared among industry players, so the

response of different organizations is likely to vary. In their paper examining

strategic responses to interest groups, Julian et al. (2008) suggest that larger, more

visible organizations are better able to accommodate external pressure, particularly if

they have the dynamic capabilities to do so, rather than core rigidities that make it

hard to adapt. The presence of cognitive factors, such as a sense that the pressure is

urgent and manageable, is also important. This variation in response – for instance

between small and large organizations, or between those organizations that perceive

the external pressures to be urgent and manageable and those that do not - reinforces

the need to understand how the real cost of e-Borders is shared and implemented by

different stakeholders.

In summary, the e-Borders programme represents a significant change in the macro-

environment in which tourism organizations operate, and reflects a broader trend

towards involving private organizations in initiatives to protect the national interest.

Although e-Borders may have made regulatory sense, its impact on the organizations

operationalizing it, and on existing business relationships (see Ball et al., 2010), is

less clear. Against a decline in market share prompted by low cost airlines and online

retailers, APD and ETS, the e-Borders requirement is another threat to tour operators

and travel agents. Therefore, it is critical to understand the impacts of this regulatory

initiative on the industry. In particular, there is a need to understand the operational

implications of collecting and transferring customer data. Not only have firms had to

change some of their internal processes, they have also had to ensure that customers

provide data at the right time, in the right format and in the right place. The new

process involved in ensuring national security therefore introduces a different tenor

into customer relationships, with potentially significant implications.

Yet, little is known about how firms are coping with the requirements or of the

adaptation process involved. Therefore, it is necessary to identify in what ways are

these government surveillance processes affecting how carriers relate to their

customers and other stakeholders. For instance, what impact does compliance have

7

operationally and on their ways of working? How do they share the requirements of

e-Borders along the supply chain? What are the implications for how they manage

their customer relationships? What knock-on effects are there on their commercial

interests and their marketing activities?

Moreover, the implication of adhering to e-Borders’ requirements is that collaboration

of other players in the carriers’ network – such as the travel agents or seat bookers – is

required. Therefore, we adopt stakeholder collaboration as the basis for our analytical

framework to examine how e-Borders has impacted the tourism industry, as described

next.

3. Stakeholder research in tourism studies: Analytical framework

Initiatives bringing together multiple organizations have been documented in various

areas of tourism management such as sustainability (e.g. Erkus-Ozturk & Eraydin,

2010) and cultural districts (e.g. Arnaboldi & Spiller, 2011). Each case, as with e-

Borders, is characterized by a complex problem that one organization alone cannot

solve. A consequence of the conditions of interdependence and uncertainty that

parties face is that they adopt collaborative strategies to optimize the payoffs in the

domain (Jamal & Getz, 1995). As Arnaboldi and Spiller (2011) acknowledge, studies

of stakeholder collaboration in tourism management research focus on three broad

areas: i) the identification of key stakeholders and their interests (e.g. Jamal, 2004;

Vernon, Essex, Pinder & Curry, 2005); ii) the collaborative process (e.g. Bramwell &

Sharman, 1999; Vernon et al., 2005) and iii) the long-term structure and outcomes of

the multi-stakeholder process (e.g. Jamal & Stronza, 2009).

The characteristics of the e-Borders initiative, the multiple parties affected within the

travel supply chain, and the nature of the collaborations occurring between them,

mean that stakeholder analysis is an appropriate analytical framework to use.

Specifically, we studied what Arnaboldi & Spiller (2011) call the ‘micro-level

dynamics’ between stakeholders, a valuable yet under-utilised research perspective in

tourism studies. Reviewing these interactions at the micro level, enables a teasing out

of the impact of this macro-level change on the affected parties. Stakeholder analysis

is appropriate for these purposes because it focuses on the power, interests,

interconnectedness and hierarchical working of the individuals and groups which

surround an organization (Eden & Ackermann, 1998; Mitchell et al., 1997). Focusing

at the micro-level also provided detailed and subtle insights into how the response to

e-Borders played out over time. We use this analytical framework to explore three

aspects of the e-Borders initiative: key stakeholders and their interests, collaborative

processes, and long-term structure and outcomes.

3.1 Key stakeholders and their interests

The identification of key stakeholders is considered pivotal in the early stages of

initiatives involving partnership and is related to issues of legitimacy and power

8

(Jamal & Getz, 1995). In this context, legitimacy consists of having the right to be

involved in the collaboration, as well as the capacity to do so (Gray, 1985).

Concerning ‘capacity’, Jamal and Getz (1995) specifically state that stakeholders

must have ‘the resources and skills needed to participate’ (p.194). A consequence of

this definition of legitimacy is that power will be unevenly distributed across

participants, with less powerful members of the network facing difficulties in getting

their interests heard (Tosun, 2000). Moreover, some members may seek coalitions

with others who share their goals and resources, which may threaten the success of

the initiative (Stoker, 2005).

The sets of ideas and material interests associated with stakeholder relationships may

hinder and threaten some of those involved (Archer, 1995). Therefore, stakeholder

analysis needs to consider negative or conflicting stakeholder relations (Friedman &

Miles, 2002). In areas where there has been a transfer of non-commercial activities to

commercial firms, as has happened for e-Borders, it may not be possible to balance

the interests of all stakeholders since private sector organizations are obligated to

carry out activities that fall outside of their commercial remits and interests

(Surveillance Studies Network, 2006; Ball et al., 2010). This recognition of

conflicting perspectives is consistent with the work of Huxham and Beech (2003) in

the strategy implementation literature. These authors suggest that the identification of

tensions is the first step in ‘practitioners’ ability to manage them in a considered way’

(p.71). e-Borders affects a variety of organizations over and above the government

and the carrier. For instance, the travel agents, tour operators and seat brokers which

sell tickets on behalf of carriers are also affected by the need for compliance. Each

organization has its own set of interests - their needs, hopes, concerns and fears

(Jamal, 2004) - which may conflict with those of other stakeholders. Although we do

not specifically collect data from customers, their interests are also strongly

implicated, as the findings will reveal.

3.2 Collaborative processes.

The original stakeholder model presented by Freeman (1984) showed the focal

organization as a hub, with the stakeholders viewed as spokes. Intuitive as this view

may be, it fails to acknowledge that stakeholders also influence each other (Fassin,

2009) and a combination of stakeholders exert more influence on a focal firm than

each separately (Mitchell et al., 1997; Friedman & Miles, 2002). Initiatives involving

collaboration are deeply affected by the distribution of power within the stakeholder

network (Arnaboldi & Spiller, 2011). Moreover, risk-management theory has also

highlighted the collaborative nature of organizational regulatory compliance and its

new role in policing private industries (see Hutter & Power, 2005; Power, 2007). The

tourism literature identifies a number of factors impacting positively on collaborations

or partnerships in the industry. Specifically, a collaborative project is more likely to

achieve its objectives when there is consensus-based decision making, information is

widely disseminated, there is heterogeneity within the network and the members’

9

roles evolve over time in line with the collaboration (Arnaboldi & Spiller, 2011; Gray,

1989; Jamal & Getz, 1995, Vernon et al., 2005).

Although for e-Borders, the responsibility for identifying suspicion and generating

alerts lies with the UK BA, it is the carriers - which we consider as the focal firm –

that are obligated to collect and submit the specific passenger data to UK BA. To

fulfill these requirements, because of the nature of the travel supply chain, the carriers

must ensure that other travel firms provide them with the required data. Thus while

the ultimate power in the system rests with UK BA, responsibility for compliance is

delegated to other stakeholders. Ongoing uncertainty surrounding the legality of e-

Borders ultimately impacts on stakeholders occupying a customer-facing role.

3.3 Long-term structure and outcomes

The long-term analysis of the initiative which is perhaps the most important issue in

terms of understanding the success of partnerships or collaborations, has hitherto not

received attention in the literature. The ambiguity and vagueness of the stakeholder

concept (Mitchell et al., 1997), allied to globalization and technological evolution

(Fassin, 2009), means that organizations have a broad range of stakeholders to

consider. Moreover, specific stakeholders can become more or less salient over time

as a result of the coalitions that are formed (Mitchell et al., 1997) or changes in the

environment (Phillips, 2003). Arnaboldi and Spiller (2011) suggest that success of

stakeholder initiatives in the long-term depends heavily on the structure of the

collaboration, the involvement of local actors and the adoption of reasonable

expectations (Arnaboldi & Spiller 2011). For example, the problems which e-Borders

has encountered since its inception, including the delay of the launch, the dismissing

of the main IT contractor, (Kollewe, 2010), and the EU legal challenges, have left

those involved facing changing requirements and considerable uncertainty. The long-

term impact of e-Borders on the relationships between stakeholders and on the

commercial interests of carriers and other travel organizations therefore merits

scrutiny. We therefore argue that there is a need to consider how the stakeholder

relationships change over time (Friedman & Miles, 2002), commercial and other

implications for these firms, and how their customer relationships are impacted.

4. Research method

4.1 Data collection

In line with other stakeholder studies and with the nascent, dynamic character of the

field, an exploratory research methodology based on key informant interviews was

adopted. Such interviews are a widely recognized and respected exploratory research

method (Kumar et al., 1993) enabling access to the experiences of a diverse range of

individuals and groups who can tell their own stories or ‘epilogues’ (Dibbern et al.,

2008, p.343). Mindful of interview saturation we devised, alongside recommended

qualitative guidelines, to gather over 30 hours of interviews (Weiss, 2008; Strauss &

10

Corbin, 1990; Silverman, 2009). Data gathering using this approach allows a

progressive and iterative approach that is helpful when studying diverse stakeholders

(Pouloudi & Whitley, 1997), and is able to generate a rich understanding of the

phenomenon of interest.

24 in-depth interviews were carried out in 10 organizations (see Table 1) between

June 2009 and November 2010, allowing changes in the stakeholder interactions and

context to be monitored. At the start of this data gathering period the implementation

of e-Borders was at an early stage and staging the interviews over this time period

allowed the researcher to witness the changing situation and its implications for

stakeholder relationships. A cross-sectional quantitative study would have been less

able to capture the issues arising from these emergent relationships. This method of

data gathering also enabled us to question the tensions highlighted by the travel

industry to the Home Affairs Committee (2009), where discrepancies between e-

Borders directives and industry capabilities had been raised. Gaining some

perspective on the tasks that the industry had now to perform and what was actually

happening in reality and ‘on the ground’, we reasoned would be better served by

examining this issue through a semi-structured interview instrument.

Undertaking this number of interviews enabled data to be gathered from a wide range

of stakeholders and from individuals in different organizational roles (e.g.

management and front-line staff), which allowed different perspectives to be

considered and increased the internal validity of the study. In common with most

research of this nature, we relied on the generosity of organizations to gain access, so

sample sizes for each stakeholder do vary. However, while representatives from all of

the stakeholders involved have not been interviewed in each organization, consistent

patterns in the data were apparent, suggesting data saturation (Bryman, 2004).

Table 1: Interviews Undertaken

Interviewee Type Number of

Interviewees

Number of

Organizations

Travel agents 7 3

Tour operators 7 1

Airlines 4 3

Government bodies 3 1

Industry bodies 2 1

Airport operators 1 1

TOTAL 24 10

A semi-structured interview schedule was applied to guide the data collection. The

following issues were probed: knowledge of e-Borders, the impact of e-Borders on

the focal firms, the groups and individuals influenced by or influencing the focal

firms, and the nature of the interconnections between stakeholders. The roles and

processes, as well as the context for the programme, its changes and impacts were

also explored. Documentary evidence complemented the interview data, including

11

supplier maps, briefing papers and internal reports, and external documents such as

government reports, white papers and media reports (Denzin & Lincoln, 1998). This

evidence ensured that a broad and detailed view of the stakeholders was achieved.

4.2 Data Analysis

Interviews were recorded unless permission for recording was refused, in which cases

contemporaneous notes were taken. Typically at least two interviewers were present,

so that notes could be compared, ensuring consistent understanding and completeness.

The three dimensions from the stakeholder framework described in the previous

section helped guide the initial coding process. That is data relating to the

identification of key stakeholders and their interests; the power distribution and

decision making mechanisms; and the long term outcomes and structure of the multi-

stakeholder process. An iterative approach as described by Strauss and Corbin

(1990), reflecting on each interview as it was undertaken was followed. Nvivo

software was used to code and analyse the date (Dey, 1993; Miles & Huberman,

1994), so that themes and patterns could emerge. Following the refinement of codes,

they were discussed by the full research team. Three main codes were central to the

findings: (i) cross-fertilization – whether information, data or practices implemented

for e-Borders has been used in other formats, such as marketing; (ii) de-stabilization –

where the standardized means of operation has been disrupted by the e-Borders

initiative; and (iii) impacts – considering how travel companies have changed the

operational practices and systems used in conducting their business.

To address bias, coding was undertaken by one researcher and independently assessed

by other members of the research team. A rich contextual picture was achieved by

combining data from multiple interviewees with differing roles and augmenting it

with documentary evidence. Including key informants from a range of organizations

increased the external validity and generalizability of the findings.

5. Findings

The findings are presented according to the three areas previously identified.

5.1 Key stakeholders and their interests

The UK BA has implemented the e-Borders programme to pursue its interests in UK

border security. While airlines, tour operators and travel agents share the Agency’s

concerns about the security of travel, they must also protect their commercial interests

by keeping their costs down, and by ensuring smooth and efficient travel experiences

for their customers. Because UK BA is delegating the collection of customer data to

the carriers, it is bringing its interests into conflict with those of a number of these

stakeholders. Table 2 describes these stakeholders and their interests in more detail.

12

Table 2: Stakeholders and their Interests

Stakeholder Stake/Interest Airline – legacy Airlines are responsible for transmitting advanced passenger

information (APIS) to UK BA before travel. Information must be

gathered at booking, separately after booking or at check-in;

adopting technical standards imposed by UK BA. Some carriers

can use their loyalty scheme to record APIS data of customers. Airline –

charter/budget Like legacy carriers, charter and budget airlines must transmit APIS

data to UK BA. Charter flight bookings are often made in groups

without data on individuals being provided. Airport operators Those providing check-in services for airlines must ensure APIS

data is collected and transmitted on behalf of the relevant airline. Tour operators Not ultimately responsible for passing APIS data to UK BA, but

operators worry about reputational damage if customers cannot

travel. Where possible, they collect data at booking, with some

providing websites for customers to provide APIS data online. Travel agents Not ultimately responsible for passing data to UK BA, but agents

also worry about reputational damage if customers cannot travel.

Originally encouraged customers to provide APIS data to tour

operators or airlines, but increasingly concerned about losing the

customer relationship. Industry bodies e.g. ABTA

Represent the views of industry groups, and have made

representations about the legality of e-Borders in Europe. Also

about technical aspects of data format and transfer, to ensure the use

of existing industry standards and to minimise additional costs. IT suppliers (Trusted Borders)

UK BA formed a consortium of IT hardware and software suppliers

to develop the data transfer, storage and analysis system. In July

2010, the programme’s main IT contractor was sacked (Millward,

2009; Ford, 2010), but was replaced in April 2011. Global Distribution

System Operators

Enable their users (airlines, travel agents and tour operators) to input

APIS data quickly and efficiently. Successfully lobbied by ABTA

to add lines of script which dealt with APIS input.

UK Border Agency Agency is responsible for visas, managing immigration and border

security, and for developing/operating e-Borders. Responsible for

examining the supplied data to identify and investigate suspicious

activity and individuals, including monitoring against watch lists. UK Government e-Borders was introduced by the Labour government in 2003,

originally as a means for immigration control. After the London

2005 bombings, security and counter-terrorism became additional

rationales. The current Conservative government continues to

support the programme. European Commission Several stakeholder groups, including the airlines and industry

groups made representations to the EC about the programme’s

legality under EU laws on free movement. EU citizens were judged

to have the right to withhold data when travelling within Europe. Customers Customers must provide their APIS data prior to travel. At present,

awareness and understanding of the scheme are low, with many

unaware that information is needed or that it is being recorded,

analysed and stored by UK BA. Even fewer customers are aware of

their right to opt-out of the scheme for intra-EU flights.

13

Compliance with e-Borders was seen as conflicting with the commercial interests of

travel firms due to the costs and other resources involved, disruption caused to

established operations and ways of working, and negative effects on customers and on

service quality. For these interviewees the quality of the customer service interaction

is seen as paramount, being widely regarded as the basis for sustaining customer

relationships and thus is central to commercial interests.

Interviewees reported tensions between the legal requirements and their commercial

obligations. Agents and partners handling customers for different airlines find the

process for providing data through varied corporate interfaces to be cumbersome.

The collection of data required by e-Borders is also time-consuming, adding ‘at least

15 minutes to the customer service encounter, no matter what medium’. (T12,

Airline).

Some staff felt that the legal requirements conflicted with the nature of their jobs.

Even though many firms had invested heavily in designed websites to meet e-Borders

requirements, customers were often slow or reluctant to understand their

responsibilities, with many contacting the travel organizations for help in-putting their

API data. As one interviewee explained,

I have had some customers that refuse: they don’t want to bring us their

passports at all, in which case I then put the onus back onto them, and it is

their responsibility. And if they haven’t done it, then they can’t come back to

us. We’ve advised them what needs to be done, and we give them the

information of what they need to do. (T22, Tour Operator)

Respondents also reported tensions with competitors, largely due to the differential

impact on incumbent firms of the costs of complying with e-Borders. While major

legacy carriers already collect the information required, other operators are still

finding ways to do so.

When you’re a small independent ski tour operator that buy ten seats of [name

of airline] a week, and that’s the entire size of your operation, your business is

run out of your back bedroom, the IT changes to make all this happen are just,

the costs just don’t stack up. (T4, Airline)

Other tensions also emerged, with retail travel agencies being reluctant for their

customers to visit the carrier’s website to provide their data, in case they lost

ownership of that customer relationship. Instead they reported passing on just enough

data to legally fulfill their obligations.

If you’re a cynical travel agent like we are, you might say, well, hang on a

moment; if they fill in all that information … what’s to stop you using that

data for other marketing activities. (T21, Tour Operator)

The lack of clarity surrounding regulations and their implementation was also a

source of tension. This was particularly so in relation to the EU ruling about the

legality of the programme, which brought significant uncertainty and changes to the

implementation work already undertaken.

14

5.2 Collaborative processes

As already explained, UK BA has set the standard for the type of passenger data to be

collected and the timing of its transmission. Establishing a consortium of suppliers to

build the data transfer, storage and analysis system was part of this process.

Considerable discussion about the system’s interface was needed, in some cases

requiring substantial investments from firms using formats which differed from the

industry standard. Discussions involving pan-industry bodies on behalf of airlines

and other travel firms also took place. Although these processes were established to

encourage collaboration between different stakeholders, they also provided insights

into some of the tensions. These stresses included the uncertainty following the

severing of ties with the main IT contractors in 2010, which resulted in delays and

increased expense across the majority of stakeholder groups. In general, there was a

feeling among respondents that the government had not taken into account how the

industry already worked. One airline executive mentioned “They don’t seem to

understand what we tell them”, another complained that when challenged during the

Regulatory Impact Assessment the government “…dismissed our comments” (T6,

Airline); while a third explained the problems that result.

We do commercial business together and our systems have to talk to each

other. Whatever we do in terms of development has to be done harmoniously

so that our systems talk (…) They failed to recognise that aspect (…) They

were having conversations with system suppliers rather than carriers. The

obligation falls on the carrier but the system supplier had to do the

development work. (T12, Airline)

Competing travel firms worked together through pan-industry trade bodies to

influence the development of e-Borders. Despite this collaboration, interviewees saw

significant disparity between the type of air carriers – legacy, leisure or budget carrier

– and their respective legacy systems’ ability to adapt to e-Borders requirements.

This discrepancy resulted in a perceived power imbalance, with legacy carriers seen

as having a greater say in the development of e-Borders. Smaller firms found it

difficult to fund the necessary investments in systems, staff and training. They also

expressed frustration with the decentralized aspects of e-Borders, whereby UK BA

make air carriers responsible for collecting and transferring data, rather than having a

unified central government portal for e-Borders information.

After the implementation of e-Borders, the relationships between businesses in the

travel supply chain and between those businesses and government were destabilised.

Although carriers have become the focal point in the emerging structure, they rely

heavily on tour operators and travel agents to collect data from customers; and on the

government to define the requirements. As one airline executive explained “The onus

is on the airline to provide the information, but they pass the request down the line so

that the buck stops with the agent” (T1, Airline). Acknowledging the difficulties that

15

could arise, some carriers referred to the need to encourage and support agents

through the process.

In terms of our agents, we talk to them about the need for them to help us with

the collection of data… We can’t force them to do it because what will happen

is they’ll just put anything in there. … if you force them against their will

they’ll just put something there that’s meaningless and that means that we’ve

god to do it again at the airport. (T6, Airline)

Carriers also have relationships with other partners, such as tour operators that book

seats on their aircraft; while airlines outsource many airport services to a third party

ground handling company. Such agents and partners provide an interface with the

customer. Competitors can also both influence and be influenced by the focal firm.

Table 3 captures some of the tensions that arise as a result of the collaborations

between stakeholders, and which are reflected by one interviewee.

Collectively, the airlines have actually made e-Borders work. I think you’ll

find that the ferries certainly, and possibly Eurostar, are doing very little,

although they represent a big chunk of what comes through the border. So,

there’s an impact and competitive situation there that annoys us a bit. (T15,

Trade Body)

16

Table 3 Collaborations and Tensions between Stakeholders

Between Air Carriers

(focal firms) and…

Description Illustrative Quotes

Government/UKBA &

System Suppliers Firms feel Government has not listened to

them and has placed all responsibility for

compliance on them.

Government has given significant influence to

system suppliers – e.g. allowing more

expensive, non-standard data interchange

protocols.

They can only put the legislation on the carrier. They’re the legal entities carrying

passengers across the borders. The tour operator, frankly the government don’t care that

[company name] sell on their 300 seats on the aeroplane to six different tour operators.

They don’t care about that. (T4, Airline)

Well, there are certain airports where it costs me money to send the data in because the

systems are set up in such a way that they are using the SITA telex network which is

expensive [as it is non-standard]. (T4, Airline)

Supply Chain Partners Small tour operators and travel agents very

concerned about damage to customer

relationship.

Inconsistent approach especially to system

interfaces – causes additional work for supply

chain partners.

Concern about margins preventing smaller

partners developing IT solutions.

The cruise company would collate the customers contact information directly and

therefore have a way of dealing with the customer directly. They may convert the

customer and it would cost [us]. (T11, Tour Operator)

If it was just a standardised one system for all of them it would be fantastic. It’s the same

for the chartered aircraft they’re giving you a bit of information to say that this [APIS

data capture] is compulsory for this destination but for these destinations it isn’t

compulsory. (T16, Tour Operator)

The difficulty with investing in a full CRM/frequent flyer system is that travel agents

margins are so small they do not have the money to invest in these systems. (T8, Tour

Operator)

Competitors Variations across competitors in how carriers

implement e-Borders – some with more care

(and hence cost) than others.

Variations in how obligations under e-Borders

are passed on to supply chain partners.

I know that certain carriers….will choose to do a shoddy job ... The [Airline Name] …

for example, all the stuff they collect online, they can send fairly easily. But anything

where the passengers don’t complete the web check-in process … they have to collect

manually at the airport. . So they might go, this manual bit’s a bit difficult; I won’t

bother. (T4, Airline)

We are having to write that into contracts [with tour operators]…But we don’t want to

do that because if another airline doesn’t write that into their contract, [operator] could

find that they’ve got better terms going somewhere else… (T4, Airline)

17

Customers Additional time and cost of service encounter.

Some airlines and airports opted to pass costs

on to customer.

Little public information – some customers

aware of need to provide API data others,

particularly infrequent flyers are not.

I was really concerned with us having to say to our customers, you’re about to go on this

holiday but you’ve got to speak to the airline to make sure that you give them your data;

because, actually, we should do that. But my challenge is that, in doing it, I’ve incurred a

lot of extra cost; and of course the travel business is a low-margin industry, and I can’t

necessarily afford that extra cost so I’m caught in this dilemma. (T21, Travel Agent)

So SITA have been out selling to all of the airports saying you need our new all-singing,

all-dancing check-in systems that are compliant with UK APIS. And some airports have

gone from having no check-in fees to fees of $2.50 a passenger. All the different airports

are now charging a dollar a passenger just to use the check-in system (T4, Airline)

If you got the passenger that just comes in off the street to do an airline booking I would

say that the public are unaware. There’d be very few people that would be walking in

and thinking I must take my passport with me down here so they have to come back

again with that. (T18, Travel Agent)

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5.3 Long term structure and outcomes

Following the initial roll out of e-Borders, carriers and other travel organizations

engaged in a process of developing and embedding their responses to the

requirements. Alongside the required operational changes, they moved to protect the

customer interface and to minimise negative effects on service quality. This

movement involved two aspects: firstly, securing the customer relationship and

secondly, exploring commercial opportunities that might arise from e-Borders.

Nevertheless, there remained a strong tension between the travel industry and e-

Borders requirements, centring on the difficulty in balancing the demands of

regulatory compliance with those of managing customer relationships. As the

following interviewee attests,

…it’s trying to get the balance between getting your customers and bringing

the booking in and then the responsibility that you have there, and then

collecting this data. What happens if they don’t give you the data? Do you

come down on the customer quite heavy-handed? Do you withhold tickets?

Do you… I don’t know. And that’s a really difficult thing (T4, Airline).

These sentiments reflect widely expressed concerns that the customer relationship

may be burdened unduly by the process of collecting APIS data. While the industry

is required to comply with e-Borders, firms are unwilling to use this obligation as a

‘big stick’ (as one interviewee described it) to gather the required data. Doing so was

seen as conflicting with the desire to provide a high quality service. Frontline

workers apparently are ever mindful that the “challenge is [to] keep up customer

services levels” and report doing what they can to advise customers on what they

must do in order to travel. There is an attentiveness to “not ruining someone’s

holiday” (T23, Tour operator), and a worry that “if you don’t get the right details in

and you’ve got a digit wrong, what the effect could be on your customer who’s at the

airport and it’s your fault” (T19, Travel agent); not least because of the desire to

encourage repeat custom. In the current climate of economic uncertainty, this need to

foster customer loyalty is particularly keenly felt.

In the early days of e-Borders, the industry pushed the APIS requirements onto the

customer and had little concern about the successful inputting of the data. More

recently, that thinking has changed, with firms much keener to take ownership of this

activity. Asking customers to input their own data online raises a number of issues.

Not all customers have computers or are familiar with using the Internet, so asking

them to input their own data may be impracticable. Although placing this burden on

the customer reduces costs, it could in the future lead to customers sourcing their own

travel products. One industry representative stated there is a feeling that we are

exposing “our secrets”. As a customer manager explains,

19

It was, push it on the customer and we’re not worried. And it was like we’ve

made the booking, our job is done. We need it to be low cost; we don’t want to

speak to that customer again if we don’t have to … Then you grow and you

realise that you need to retain customers, we need to nurture relationships, we

need to lower the acquisition costs of getting these customers. So every

opportunity to contact them was a good opportunity. (T28, Operations

Director)

Interviewees acknowledged that data collected for e-Borders cannot be used for

marketing purposes, with some expressing doubt about the extent to which it ever

would be commercially beneficial. There was even a sense of being back-footed by

the changes, with many speaking of an industry that has not developed some of the

more aggressive marketing strategies currently in practice in other industries.

However, the fact that APIS has increased the level of customer interaction is an

unexpected benefit that is seen as bringing opportunity for securing the customer

relationship. This opportunity is, however, accompanied by concerns about

‘ownership’ of that relationship. We found evidence that APIS requirements are

leading to turf wars as travel organizations grapple with whether “they tell the

customer to go somewhere else to input the data or do they collect it there and then?”

(T11, Tour Operator). Some carriers have dealt with such data concerns by

developing microsites to ensure that the information is held securely, while others

spoke of their procedures for deleting data after passengers have travelled. A large

travel agent captured the general nervousness around this issue, summarising the

situation from their viewpoint in relation to tour operators.

so our problem, immediately, with someone like Thomas Cook, was, we don’t

really want our customers going onto your main website, putting all of their

data into you website, just to meet the obligations; because in filling in that e-

form on your website, actually they are getting one step closer to becoming

direct customers of you, as opposed to our customer … It’s the retail travel

agent’s paranoia but it’s a valid paranoia. (T21, Travel Agent)

It is responses such as these that are driving the industry’s longer term response to e-

Borders. Firstly, there are concerns about ‘ownership’ of the customer relationship

and secondly, a desire to explore any commercial opportunities arising from the

additional customer contact. Despite, as mentioned before, APIS collection being “a

good excuse to get in touch with your customers again” (Airline T4), not all call

centre staff are making the most of this opportunity. One frontline team leader

expressed frustration at the situation,

But more I think it’s a sales opportunity for them, and I try and tell them in

their call coaching sessions to sell… Try and sell them something. A call is a

call at the end of the day... (T13, Tour Operator)

20

Even though using APIS calls as a selling opportunity is considered important,

carriers are not yet using APIS data directly for marketing purposes. Instead the

emphasis is on selling ‘extras’, such as the choice of seat or meal on flights. Rather

than retaining information for future marketing, the industry is concentrating on the

immediate sales or on improving existing bookings. As the following interviewee

acknowledges,

Regarding APIS, it has had very little impact on the marketing function. It

does not feature anywhere in marketing data. Branches were alerted to it in a

communication and some online training (which branch managers requested)

from the marketing dept. (T24, Tour Operator)

Cross-selling or selling ‘add-ons’ is already common practice in the industry, so it is

not surprising that the selling opportunities which the APIS contact creates has been

noticed. As one informant explains,

Historically, you go into travel agents and you would buy a ticket, the tickets

would turn up in the post two weeks before you travel. You would never speak

to a travel agent, never speak to your tour operator and never speak to your

airline until you get to the check-in desk. And that was it. But now passengers

who book direct, can you give us your APIS details, and while you’re doing it,

do you fancy buying a leg-room seat? Do you fancy buying car hire? Do you

want to buy some insurance? Great cross sale opportunity, absolutely

fantastic cross sale opportunity. (T4, Airline)

There is a growing realisation that APIS requirements are accompanied by

opportunities to develop customer relationships and expand sales. Initially, there was

little evidence of firms using the APIS process to benefit commercially. More

recently, attention has shifted to using e-Borders calls to sell ‘add-ons’ to existing

customers. Although the full marketing potential of the initiative has yet to be

realized, the industry is now exploring a number of marketing benefits. For example,

one organization is working on a ‘known traveller’ approach, where certain benefits

are extended to customers who are prepared to share particular personal data. In

addition, links with ‘known’ smartphones are being explored: in this instance, the

details stored by the phone will replicate the details held on a passport (T27, CEO

Industry subsidiary). Thus we are seeing a resurfacing of the commercial interests of

carriers and travel operators in how they are implementing their e-Borders response.

6. Discussion and Conclusions

Tourism is an important economic activity, though policy makers often prioritize

other issues (Ashworth & Page, 2011). This study describes a change in the legal

macro setting for tourism, which results from a complex problem of national security

that cannot be solved by the government alone. Due to their proximity to the end

21

user, carriers have been enlisted to develop, implement and finance traveller

monitoring systems, effectively delegating and internalizing some of the costs of

providing effective ‘national security’. The problem of reconciling public vs. private

costs and benefits is familiar in tourism (Ashworth & Page, 2011), and

understandably creates resentment among industry players. However, safety is a key

variable in destination choice, regardless of the tourist’s demographic characteristics

(Smith & Carmichael, 2005). While all stakeholders would insist upon safety as a

high priority, a clearer understanding of the real costs – including the intangible costs

– to stakeholders of these changes is of significance to both practitioners and

researchers.

Our study has explored the impact of e-Borders in the firm’s interactions with a

network of other stakeholders in order to address our research question: What is the

impact of e-Borders on the carriers’ relationships with their customers and other

stakeholders? By examining the different interests and collaborative process among

stakeholders we are able to explain the medium-term outcomes and structures arising

from e-Borders. Using a stakeholder framework to study these effects and by

conducting our data collection throughout the early stages of e-Borders

implementation, we have been able to follow and reflect the changes arising from

compliance. Gathering data over a three-year period coinciding with this bedding-in

phase, has also yielded insights into what has taken place in process terms. We argue

that the carriers, and to some extent the other travel organizations, have engaged in

response to the e-Borders initiative in a process we describe as recognizing,

rationalizing and refashioning. This process has been motivated by the desire of

firms to manage the negative consequences arising from the e-Borders initiative,

return their commercial interests (and those of their customers) to the fore, and to

restore equilibrium to the disrupted system. While there is a sequential character to

the process that we describe, there is also evidence that some stages are overlapping.

6.1 Recognizing

We refer to the first stage of the process as recognizing, at which point the rules of

engagement are established and the foundations are laid for the power and decision

making between stakeholders. It is now that the different stakeholders learn about the

expectations and possible implications of compliance requirements. Practical

discussions ensue between stakeholders concerning how the initiative could be

managed and what implications there might be for operational processes and ways of

working. Importantly, our study has identified that a range of intangible costs impact

upon service delivery. Chief among these are the additional transaction time, the

complex process involved, customer confusion and the possibility of mistakes. These

factors impact negatively on the customer interaction, which is of considerable

concern in a sector that increasingly emphasizes service quality and the customer

experience (Shaw, Bailey, & Williams, 2011).

22

6.2 Rationalizing

The process of rationalizing follows, although aspects of this phase may run

alongside the recognizing stage. Rationalizing involves aligning the e-Borders

requirements with operational factors, with the consequence that stakeholders ensure

compliance by modifying existing processes, technology and ways of working. We

find this process to be difficult and costly, that customer service is implicated, and

that commercial interests are threatened. In the process of meeting the e-Borders

requirements there is a destabilization of the overall system as the power relationships

between stakeholders play out. The collaboration process is therefore also

characterized by a series of tensions. The relationships with the government and IT

supplier consortium are particularly strained as is common in circumstances where

power brokers have a disproportionate influence (Jamal & Getz, 1995). This strain

impacts negatively on the interaction with customers, through the changes and

uncertainty it brings. The relationship between the focal firm and their agents and

partners becomes critical, as the co-operation of organizations in direct contact with

customers can significantly smooth API data collection. Moreover, these parties also

face technology, personnel and recruitment costs from e-Borders. Therefore,

developing a strong relationship with these organizations is likely to benefit both the

passenger carriers and their customers. The benefits of such collaborative networks

between competitors have been documented in other instances of public tourism

goods, such as sustainable tourism development (Erkus-Ozturk & Eraydin, 2010). If

carrier and competitors come together they have more power to influence the

government and the emerging technical solution, which is beneficial for all involved.

Even so, imbalances in power may remain, with some smaller operators benefitting

less than their larger counterparts.

6.3 Refashioning

We find that carriers and other travel organizations respond to the challenges of e-

Borders by refashioning their ways of working. Although much of this refashioning

takes place after the operational implementation associated with rationalizing, some

of these activities run alongside the earlier phase. During refashioning, firms seek

solutions to the serious, costly, destabilizing outcomes of compliance; exploring how

high levels of customer service can be delivered within the regulatory constraints, and

pursuing new avenues to develop commercial opportunity. Two principle motivators

drive this refashioning phase. The first is that customers must be nurtured, that their

interaction with the organization should be carefully managed and should not be

jeopardized by compliance. Although carriers initially tried to shun APIS costs by

passing them on to travellers, the mood quickly changed amidst angsts about

customer retention, to easing the burden of compliance for customers. The second

motivator is the desire to explore whether e-Borders can generate commercial

opportunity for carriers and travel organizations. Although technically the answer is

‘no’ (as evidenced by UK BA’s views on this matter), what is happening in practice is

rather different. We found little evidence e-Borders being used to generate

23

commercial opportunity during our initial data gathering, yet in the later interviews

when e-Borders had become more embedded, firms were using the customer contact

created by compliance to cross sell. We suggest that such activity is increasing and

that it will become more routinized and strategic over time.

In this regard, just as firms must respond to other changes in the macro environment,

they are finding ways to adjust to the disruptions caused by e-Borders. When such

changes occur, they may be regarded as either (or both) a potential threat or potential

opportunity. What is distinctive about e-Borders, however, is that compliance is

compulsory and enforced, that it must take place within the UK BA timeframe, and

according to the mechanics laid down in the rules. Furthermore, all carriers operating

into and out of the UK are facing the same regulatory changes. Consequently, there is

little flexibility for some of these operators to benefit at the cost of the others. Even

so, as Smart and Vertinsky (1984) would expect, firms have initially responded to the

disruption by engaging in short-term ‘fire-fighting’, but are now adapting to restore

their commercial interests and to reinstate the status quote over time. For example,

some firms are now considering offering ‘pay for fast track’ services so that

customers are not inconvenienced by security requirements. The variation in

response (as Julian et al., 2008, suggest), may be due to a range of factors including

the size or visibility of the organization, its resources and capabilities, and the

perceived urgency and manageability of the situation.

7. Conclusion, implications and further research

In conclusion, our study has explored how the implementation of the UK e-Borders

programme has impacted passenger carriers’ relationships with other stakeholders. By

reflecting upon the stakeholder interests, the power and decision-making at play, and

on the medium-term outcomes arising from the process, our findings have brought

into sharp focus a range of emerging tensions. A greater understanding of these

tensions and their causes, along with possible paths to their resolution, are of

considerable significance to managers in the tourism sector who are tasked with

balancing compliance needs with commercial interest.

Our findings have a number of implications for travel firms. Firstly, while the

immediate pressure to achieve regulatory compliance may make it beneficial to work

in partnership with other carriers and travel organizations, these benefits are likely to

be short term. Such partnerships are motivated by a desire to ‘protect’ the industry as

a whole, with those involved sharing interests in minimizing disruption and the costs

of compliance. However, once the initial implementation phase has passed, firms are

likely to move quickly to restore their individual commercial interests. Vigilance is

needed during this period, as firms ensure that they make the necessary operational

changes, while protecting their customer relationships from opportunistic competitor

activity. Secondly, the impact of the e-Borders initiative is unlikely to be evenly

shared. As we have seen, although the responsibility for compliance rests with the

24

carriers, all parts of the supply chain are implicated. Smaller firms, those with fewer

resources and with less-developed customer management systems are likely to find it

more difficult to adapt and may have less influence over the changes. Travel agents,

for example, must ensure that customers provide their data by complying with a

variety of different systems set up by the carriers. In a situation where they have

limited control over proceedings, they must also do what they can to protect their

customer base. Finally, firms which move quickly to ensure that call centres are

appropriately resourced and staff are suitably trained to deal with e-Borders queries,

are also more likely to benefit from commercial opportunities, such as cross selling.

While this study did not directly examine the views of consumers, future research

could examine the changing behaviour of travellers in relation to the shifting

regulatory environment, considering whether the way travel products are bought or

their relationships with travel firms have been affected. A quantitative research

design could yield interesting insights into these behavior patterns across different

customer groups.

There is also scope for further longitudinal research examining the e-Borders

stakeholders featured in this study. Gathering data that captures these multiple

perspectives over a three-year period has revealed how the responses of different

stakeholders change over time to restore equilibrium to the system. Extending the

period of data gathering would enable further stakeholder reactions, such as in

relation to the evolving situation regarding the legality of e-Borders, to be captured.

Researchers examining other situations where private organizations are mandated to

implement government policy might for similar reasons, consider using a comparable

longitudinal research design.

Finally, our research has focused on the implementation of a particularly regulatory

change affecting the UK and those travelling or supplying travel services to and from

it. Although we make no claims about the generalizability of our findings to other

contexts, tourism is a global phenomenon and we believe that travel firms in other

situations where regulatory disruption is taking place, may respond in similar ways.

We are also aware that while our study has primarily focused on UK stakeholders, the

changes in the UK will also have impacted other players elsewhere. Therefore there

is potential both to carry out other stakeholder studies in other countries experiencing

similar change and also to consider the impact of e-Borders beyond the UK.

The longer term impacts of e-Borders are unclear. The scheme is technically illegal

within the boundaries of the European Union and unless carriers implement the

stipulation that EU citizens may opt out of providing APIS data in advance, it will

remain so. Carriers and their supply chains are facing huge additional systems

adaptation costs, which they will have to absorb, if they are forced to implement the

opt out. Ferries and rail operators are still reluctant to invest in compliant systems

due to these legal uncertainties. The UK BA has suffered in the current round of

25

budgetary cuts and is under continual scrutiny from the Home Affairs Select

Committee in relation to the development of the system. Given the demise of other

government sponsored databases, such as the National Identity Register, which was

similarly at odds with European human rights principles, an eerie quiet has descended

around the issue as if to stifle public discussion while the travel industry ‘just gets on

with it’. It is therefore difficult to gauge the impact of eBorders, but a total

information collection approach to border security which is at odds with European

human rights principles may yet prove controversial for potential UK visitors (Pearce

2005).

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